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Injury and illness recordkeeping requirements for sheltered workshops

Summary A state labor official asked whether sheltered workshops had to keep OSHA injury and illness logs. OSHA said workshops properly classified under SIC 8331 were exempt unless the Bureau of Labor Statistics contacted them for its annual survey. It cautioned that the workshop’s primary purpose had to be job training and vocational rehabilitation rather than manufacturing.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1993-01-26-7
Date issued
January 26, 1993
Status
Archived by the agency
OSHA marks this page as an archive document and says it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Exemptions
Source
View the official document

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 26, 1993

Mr. Brad Brown
Planning & Research Associate II
Department of Labor
Bureau of Labor Standards
Research & Statistics Division
[Recipient address omitted]
Dear Brad:

Thank you for your letter dated January 12, requesting an interpretation concerning OSHA recordkeeping requirements as applied to sheltered workshops.

As mentioned in your letter, the Standard Industrial Classification for sheltered workshops is 8331, no matter what specific activity they perform. As found on page 5 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, SIC 8331 is an exempt industry. Therefore sheltered workshops need not keep OSHA injury and illness records unless contacted by the Bureau of Labor Statistics to participate in their Annual Survey.

Care must be taken when assigning SIC code 8331. It must be established that the primary function of the company is to provide job training and vocational rehabilitation, and not the manufacture of a product.

I hope you find this information useful. If you have any further questions, please call us at Area Code (202) 219-6463.

Sincerely,
Stephen A. Newell
Director
Office of Statistics

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